Davies Group HR Privacy Notice for California Residents

Last Updated: July 16, 2024

This HR Privacy Notice for California Residents (“HR Privacy Notice”) describes the types of personal information we collect about California residents who are (1) Davies Group Ltd. (“Davies”) employees, owners, directors, officers, contractors, and applicants (collectively, “Davies Personnel”), (2) emergency contacts of Davies Personnel, and (3) individuals related to Davies Personnel for whom Davies administers benefits (collectively with Davies Personnel, “HR Covered Individuals”).

Davies Personnel are responsible for providing this HR Privacy Notice to any HR Covered Individual whose personal information is provided to Davies by Davies Personnel. Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information

Davies may collect (and may have collected during the 12-month period prior to the Last Updated date of this HR Privacy Notice) the following categories of personal information about HR Covered Individuals:

• Identifiers: identifiers, such as a real name, alias, postal address, unique personal identifier (g., a device identifier, employee number, unique pseudonym, or user alias/ID), telephone number, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, date of birth, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number and debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Device/Network Data: Internet and other electronic network activity information, including, but not limited to, IP address, device identifiers, browsing history, search history, and information regarding your interaction with websites or applications.
• Audio/Visual Data: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information, such as compensation, benefits and payroll information (g., salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title and job description), performance-related information (e.g., evaluations and training), talent management information (e.g., resumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), emergency contact information, and dependent information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, attitudes, abilities, and aptitudes.

Davies may use (and may have used during the 12-month period prior to the Last Updated date of this HR Privacy Notice) personal information for the purpose of carrying out and supporting HR functions and activities, including the uses described below. In addition to general HR purposes, we list below relevant “business purposes” as they are described in the CCPA.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain personal information about HR Covered Individuals for as long as necessary to fulfill the purpose for which it was collected, taking into account the following:

• Adhering to retention periods established under applicable law or necessary to comply with legal obligations, or to establish or defend legal claims;
• In line with industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Identifying risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• Recognizing design considerations/limitations; and
• Analysing the costs associated with continued processing, retention, and deletion.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this HR Privacy Notice, Davies may have obtained personal information about HR Covered Individuals from the following categories of sources:

• Directly from you;
• Your devices;
• Family or friends who provide information about you, for example, in connection with our provision of benefits or services;
• Our affiliates and subsidiaries;
• Service providers, contractors and other vendors who provide services on our behalf;
• Customers or business partners who provide information about you, such as when they provide feedback;
• Internet service providers (“ISPs”);
• Operators systems and platforms;
• Government entities;
• Social networks; and
• Data brokers, such as credit bureaus, credit reporting service providers and background check services.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this HR Privacy Notice, Davies may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this HR Privacy Notice, we may have disclosed personal information about HR Covered Individuals to government entities, and with third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures. We will only process your personal data in line with the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose, and that purpose is compatible with the original purpose.

Davies does not sell or share, or process for cross-context behavioral advertising purposes, personal information about HR Covered Individuals.  We do not knowingly sell or share the personal information of minors under 16 years of age.

Your California Privacy Rights

If you are an HR Covered Individual, you have certain choices regarding your personal information, as described below.

• Right to Know: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
• Right to Correct: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Right to Delete: You have the right to request that we delete certain personal information we have collected from you.
• Right to Opt-out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
• Right to Limit Sensitive Data: You have the right to request we limit the use and disclosure of sensitive personal information we have collected from you.

How to Submit a Request

To submit a request to exercise any of the rights mentioned above (right to know, correct, delete, opt out of sale or sharing, or right to limit sensitive data) please complete our webform through the link here or call us at:

(800) 490-5759. You can opt-out of the sale or sharing of your personal information by clicking to “Do Not Sell or Share My Personal Information” or by using the Global Privacy Control signal.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to sign in to your Davies company account. If you do not have a Davies company account and you request access to, correction of or deletion of your personal information, we may require you to authenticate your email address and provide information about your employment dates with Davies, prior payments from Davies, prior correspondence with Davies or other details about your work for or relationship to Davies.  In addition, if you do not have a Davies company account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the HR Covered Individual whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

How To Contact Us

If you have any questions regarding this HR Privacy Notice for California Residents or our privacy practices, please contact us at usprivacy.dpo@us.davies-group.com.